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Data Protection and Privacy Policy for USU Software AG and USU GmbH

We at USU are delighted at your interest in our Internet presence and our services. Protection of personal data has a particularly high priority for us. This policy aims to inform you about whether and how personal data is collected and processed in connection with the use of our Internet presence and about your rights as a data subject in this context.

As the controller, USU Software AG has implemented numerous technical and organizational measures to ensure that personal data processed on this website is protected as fully as possible. Nevertheless, data transfers over the Internet may fundamentally have security loopholes, and thus total protection cannot be guaranteed.

I. Name and address of the controller responsible for processing data

With regard to the use of our website www.usu.de and its subpages, as well as the linked websites and social media presences of USU Group companies, the controller within the meaning of the General Data Protection Regulation (GDPR) and other data protection legislation applicable to us is:

II. Collection and storage of personal data in connection with visits to our website; nature and purpose of its use

1. Security

If personal data is transmitted to us over our website, we use numerous secure technologies, in particular the Transport Layer Security (TSL) and Secure Socket Layer (SSL) transfer protocols. All information and data transferred using these secure methods is encrypted before being sent to us. The IP address of the system used to call the website is transmitted to us so that our users – and USU as well – are protected against misuse.

2. Recording of general data and information

Whenever it is called, our website records a number of items of general data and information that are stored in the server’s log files. The following may be recorded:

The types of browser used and their versions

The operating system used by the system accessing our website

The website from which a system accesses our website (referrer)

The subpages accessed by a system on our website

The date and time our website was accessed

The Internet Protocol (IP) address of the system calling our website

The Internet service provider of the system accessing our website

Other similar data and information that helps repel threats in the event that our IT systems are attacked.

We do not use this general data and information to identify the data subject. This information is required instead (1) to deliver our website’s content correctly, (2) to optimize our website’s content and advertising for it, (3) to ensure that our IT systems and our website’s technology keep running properly, and (4) to provide law-enforcement authorities with the information required to prosecute any cyberattacks that occur. This data and information, which is collected anonymously, is therefore analyzed statistically, in part with the objective of increasing data protection and data security at our company and thus ultimately ensuring an ideal level of protection for the personal data we process. The anonymous data in the server log files is stored separately from all personal data provided by a data subject.

3. Cookies

Our website uses cookies, which are text files that are placed and stored by a web browser on a computer system. Many websites and servers use cookies. Many cookies contain a cookie ID that uniquely identifies the cookie. It consists of a character string that permits websites and servers to be linked to the specific web browser in which the cookie was stored. As a result, the websites visited and servers can distinguish the data subject’s individual browser from other web browsers containing other cookies. A particular web browser can be recognized and identified by the unique cookie ID.

By using cookies, USU can provide users of this website with more user-friendly services, which would not be possible without the placement of cookies. A cookie can help us optimize the information and offers on our website to suit users’ needs. As already mentioned, cookies enable us to recognize users of our website. The purpose of that is to make our website easier to use. If you call a website that uses cookies, you do not need to enter your access data again every time you visit it, for example, since the website and the cookie stored on your computer system do this for you. Another example is the cookie of a shopping cart in the online shop. A cookie helps the online shop remember the articles a customer has placed in the virtual shopping cart.

Data subjects can prevent cookies from being placed by our website at any time by making the relevant settings in their web browsers and thus permanently objecting to the placement of cookies. They can also, at any time, delete cookies that have already been placed by using their web browsers or other software programs. This is possible in all common web browsers. If data subjects disable cookies in their web browsers, they may not be able to use all the functions of our website in full.

4. Registration on our website

Data subjects can register on our website, which involves providing personal data. The personal data sent to us is defined in the input screen used for registration, and once entered it is collected and stored solely for the specified purpose. We can transmit it to one or more processors so that it can be processed as stipulated, or to a USU Group company, if that is necessary to fulfill the specified purpose. If data subjects register on our website, the IP address assigned by their Internet service providers (ISP) to the system they use is stored along with the date and time of registration. This data is stored because it is the only means of preventing misuse of our services and so that it can be used to investigate criminal acts, if necessary; in this respect, the storage of this data is necessary as a safeguard for the controller. By registering and voluntarily disclosing their personal data, data subjects help us offer them content or services which, due to their nature, can only be offered to registered users.

5. Subscription to a newsletter

Users can subscribe to newsletters on our website. The personal data sent to us when a newsletter is ordered is as defined in the input screen used for subscribing. USU regularly informs its customers and prospects about what the company has to offer by means of a newsletter. Data subjects can only receive the newsletter if (1) they have a valid e-mail address and (2) they have registered for the newsletter or have an active contractual relationship with USU and the newsletter in question contains information of relevance to the contractual partner. The law requires us to send a confirmation message to the e-mail address the data subject has specified when subscribing to the newsletter (double opt-in method). This confirmation message helps us verify that the owner of the e-mail address is the data subject and has authorized receipt of the newsletter.

If data subjects register for the newsletter, we also store the IP address assigned by their Internet service providers (ISP) to the system they used at the time of registration, as well as the date and time of registration. This data must be collected in order to ascertain any (possible) misuse of a data subject’s e-mail address at a later time, and thus is a legal safeguard for the controller.

The personal data collected during registration for the newsletter is used solely for sending out the newsletter. In addition, newsletter subscribers can be notified by e-mail if this is necessary for the operation of the newsletter service or if registration is required, such as may be the case if there are changes in the newsletter offer or technical circumstances. The personal data collected as part of the newsletter service is not transmitted to third parties, with the exception of the persons responsible for the newsletter’s contents at the USU Group. Data subjects can cancel their subscriptions to the newsletter at any time. Data subjects can, at any time, withdraw their consent to storage of personal data they have given us (solely) for newsletter distribution. Every newsletter contains a link that can be used to withdraw consent. Data subjects can also cancel their subscriptions to the newsletter at any time directly on the controller’s website or use other means to notify the controller of their requests to cancel it.

6. Tracking

USU’s newsletters contain tracking pixels. A tracking pixel is a miniature graphic that is embedded in e-mails sent in HTML format to enable recording and analysis of log files. This permits statistical evaluation of the success or lack of success of online marketing campaigns. The embedded tracking pixel allows USU to recognize whether and when a data subject has opened an e-mail message and what links in the e-mail were called. We store and analyze the personal data collected by tracking pixels contained in the newsletters in order to optimize newsletter distribution and tailor the content of future newsletters even better to the interests of the data subject. However, data subjects can, at any time, withdraw the separate consent they have given to this practice, which uses the double opt-in method. When a subscription to the newsletter is canceled, USU automatically interprets that as a withdrawal of such consent.

Our website uses the tracking pixel technology of WiredMinds AG to analyze user behavior. Data is collected, processed and stored and used to create use profiles under a pseudonym. These use profiles are anonymized completely where possible and sensible. This may require the use of cookies, which are small text files that are stored in the visitor’s web browser and enable it to be recognized. The collected data, which may also include personal data, is sent to WiredMinds or collected directly by WiredMinds. WiredMinds may use information left as a result of visits to websites to create anonymized use profiles. The data obtained in this way is not used, without the separate consent of the data subject, to identify the visitor to this website personally, and it is not combined with personal data about the bearer of the pseudonym. Where IP addresses are collected, these are rendered anonymous immediately through the deletion of the last number block. Permission to collect, process and store the data may be revoked at any time with future effect under the following link: Exclude from website tracking.

7. Contacting us via the website

In compliance with statutory requirements, our website contains information that enables rapid electronic contact with us and allows the other USU Group companies to communicate directly with us. That information likewise comprises a general e-mail address. If data subjects contact the controller by e-mail or using a contact form, the personal data they send is automatically stored. Personal data given to the controller voluntarily in this way is stored so that the request can be handled or the data subject contacted.

8. Comment function in the blog on the website

On our website, we offer users the possibility of leaving individual comments on individual posts in a blog there. A blog is a portal on a website that can usually be viewed by the public and in which one or more persons (called bloggers) post articles or write down their thoughts in what are termed blog posts. Third parties can usually submit comments to the blog posts. If data subjects leave comments in the blog on our website, the comments they leave, as well as details of the time they entered them and their chosen user names (pseudonym), are stored and published. The IP address assigned by the Internet service provider (ISP) to the data subject’s system is also logged. The IP address is stored for security reasons and for the eventuality that a data subject submits a comment that infringes third-party rights or posts unlawful content. In other words, this personal data is stored in the controller’s interests as exculpatory evidence in the event of a violation of the law and is not transmitted to third parties unless prescribed by law or to help the controller defend against legal action.

9. Additional data protection regulations on the use of Google Analytics (with an anonymization function)

The component Google Analytics (with an anonymization function) is integrated in our website. Google Analytics is a web analytics service. Web analytics is the collection, gathering and analysis of data on the behavior of visitors on websites. Among other things, a web analytics service records data on the website from which a data subject accesses a website (referrer), which subpages on the website are accessed, or how often and for how long a subpage was viewed. Web analytics is mainly used to optimize a website and to conduct a cost-benefit assessment of Internet advertising. The operator of the Google Analytics component is the company Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043-1351, USA. We use Google Analytics with the “_gat._anonymizeIp” extension. With this extension, Google truncates and anonymizes the IP address of the system used by the data subject if our website is accessed from a Member State of the European Union or another country that is party to the Agreement on the European Economic Area.

The purpose of the Google Analytics component is to analyze visitor flows on our website. Among other things, Google uses the data and information it gathers for evaluating the use of our website, compiling online reports on activities on our web pages for us, and providing services related to the use of our website. Google Analytics places a cookie on the data subject’s IT system. Cookies have already been explained above. Placement of the cookie enables Google to analyze the use of our website. Whenever a data subject calls an individual page of our website that we operate and on which a Google Analytics component has been integrated, the web browser on the data subject’s IT system is automatically prompted by the Google Analytics component to transmit data to Google for the purpose of online analysis. As part of that technical process, Google gains knowledge of personal data, such as the IP address of the system used by the data subject. This helps Google trace the origin of visitors and clicks and thus, for example, enable commission to be charged. The cookie is used to store personal information, such as the time at and place from where our website was accessed and how often the data subject visited it. Whenever our web pages are visited, this personal data (including the IP address of the system used by the data subject) is transferred to Google in the United States of America and stored by Google there. Google may transmit the personal data collected by this technical method to third parties.

As described above, data subjects can, at any time, prevent cookies from being placed by our website by making the relevant settings in their web browsers and thus permanently objecting to the placement of cookies. Such a setting in the web browser would also prevent Google from placing a cookie on the data subject’s IT system. In addition, a cookie that has already been placed by Google Analytics can be deleted at any time in the web browser or by using other software programs.

Moreover, data subjects can object to and prevent recording of the data generated by Google Analytics and relating to the use of this website and the processing of that data by Google. To do that, a data subject must download and install a browser add-on under the link tools.google.com/dlpage/gaoptout. This browser add-on notifies Google Analytics by means of JavaScript that no data and information on visits to websites may be transmitted to Google Analytics. Installation of the browser add-on is interpreted by Google as an objection to the recording of data. If the data subject’s IT system is deleted, formated or reinstalled later, the browser add-on must be installed again in order to disable Google Analytics. If the browser add-on is deinstalled or disabled by data subjects or other persons in their sphere of influence, the browser add-on can be reinstalled or reactivated.

10. Links to third-party websites

USU’s website contains links to other websites. By clicking these links, you leave the USU website. The presence of these links on USU’s website does not mean that USU supports, promotes or claims ownership of the sites to which we provide links. These linked sites are beyond the control of USU and USU accepts no responsibility for these linked websites, in particular for their content, their data protection and privacy policies or any possible transmission of data by them.

Under the following links, you can view the data privacy policies of the social media channels that have links on our websites:

III. Collection and processing of personal data for job applications and in the application process

We collect and process personal data from job applicants so as to handle the application process for all companies belonging to the USU Group. That may also be done electronically. That is the case in particular when applicants send their application documents to the controller electronically, such as by e-mail or using a form on the website. If the controller concludes an employment contract with an applicant, the data provided is stored for use as part of the employment relationship in compliance with statutory provisions. If the controller does not conclude an employment contract with an applicant, the application documents are destroyed or erased when a decision to reject the applicant is made, unless the controller has other legitimate interests for not doing do. A legitimate interest here is, for example, the requirement of furnishing proof in the event of possible legal action under the German General Act on Equal Treatment (AGG).

IV. Collection and processing of personal data as part of commissions

Personal data is collected and processed as part of commissions on the basis of the requirements for the specific commission and is usually done by the respective USU Group company itself as the controller. In this regard, any processing activities by USU Software AG are carried out solely in its capacity as a “processor.”

V. Legal grounds for processing

The legal basis for our company for processing operations where we obtain consent to process data for a specific purpose is Article 6 (1) (a) GDPR.

If personal data has to be processed for the performance of a contract to which the data subject is a party, such as is the case with processing operations required to supply goods or provide another service or consideration, the legal basis for that is Article 6 (1) (b) GDPR. The same applies to processing operations required for performance of steps prior to entering into a contract, such as is the case when we receive inquiries about our services.

If we are subject to a legal obligation that requires processing of personal data, such as to fulfill tax-related obligations, the basis for that is Article 6 (1) (c) GDPR.

Finally, processing operations may be based on Article 6 (1) (f) GDPR, which is the legal basis for processing operations that are not covered by any of the above legal grounds, when processing is necessary to safeguard the legitimate interests of a USU Group company or a third party (e.g. a customer), unless such interests are overridden by the interests or fundamental rights and freedoms of the data subject. In relation to our website, that applies in particular to processing operations in accordance with Section II of this Data Protection and Privacy Policy. We are, in particular, permitted to carry out such processing operations because they have been mentioned specifically by the European legislator, which was of the opinion that a legitimate interest could be assumed if the data subject is a customer of the controller. A further legitimate interest is to conduct our business activity for the well-being of our employees and shareholders, as well as processing for direct marketing purposes, in particular to send information on products and services, invitations, information on events and the like.

VI. Transmission of personal data

Personal data is transmitted to third parties only if that is authorized under data protection law, for example on the grounds specified under Section V of this Data Protection and Privacy Policy, and to external service providers for processing on behalf of the controller and subject to its instructions. In general, data is not processed outside the EU or EEA. If data needs to be transmitted to a country outside the EU or EEA in an individual case, this is done solely on the basis of the EU standard contractual clauses or to countries for which an adequacy decision has been adopted by the EU and under a contract on processing on behalf of the controller. We will not sell your personal data to third parties or otherwise market it.

VII. Length of time for which personal data is stored

The criterion for storing personal data is the respective statutory retention period. When this period ends, the data in question is routinely deleted, if and to the degree that it is no longer required to perform a contract or steps prior to a contract. However, data will continue to be stored if the data subject’s interests in having the data deleted are overridden by the legitimate interests of the controller, such as to safeguard its means of defending against legal action and indemnity insurance cover for potential rights of recourse by customers and/or data subjects where the period of limitation has not yet expired. If there is no such legitimate interest, this data is also routinely erased.

VIII. Rights of data subjects

Data subjects have the right to:

Demand, in accordance with Article 15 GDPR, information on and access to their personal data we have processed. In particular, they can demand information on the purposes of processing, the category of personal data, the categories of recipients to whom their data has been or will be disclosed, the length of time it is to be stored, the existence of a right to rectification, erasure or restriction of processing of their data or to object to its being processed, the existence of a right to lodge a complaint, and the origin of their data if it is not collected by us, as well as the existence of automated decision-making, including profiling, and any meaningful information about the details of that (we point out here that we do not use profiling);

Demand, in accordance with Article 16 GDPR, immediate rectification of incorrect personal data we have stored concerning them and demand that incomplete personal data is completed;

Demand, in accordance with Article 17 GDPR, erasure of personal data we have stored concerning them, unless processing of it is required for exercising the right of freedom of expression and information, for compliance with a legal obligation, for reasons of public interest, or for the establishment, exercise or defense of legal claims;

Demand, in accordance with Article 18 GDPR, restriction of processing of their personal data, if they dispute the correctness of the data, processing of it is unlawful, but they oppose its erasure and we no longer need the data, but they need it to establish, exercise or defend legal claims, or they have objected to processing of their data in accordance with Article 21 GDPR;

Receive the personal data they have provided, in a structured, commonly used and machine-readable format or demand that their data be transmitted to another controller in accordance with Article 20 GDPR;

Revoke their consent to processing of their data at any time in accordance with Article 7 (3) GDPR. As a consequence, we will, with future effect, no longer be allowed to continue processing the data on the basis of their prior consent; and

Lodge a complaint with a supervisory authority in accordance with Article 77 GDPR, which can usually be done with the supervisory authority responsible for the person’s habitual residence, place of work or our company’s domicile. In the latter case, the authority is: Landesbeauftragte für den Datenschutz und die Informationsfreiheit (The State Commissioner for Data Protection and Freedom of Information) Baden-Württemberg, Königstrasse 10 a, 70173 Stuttgart, Germany

IX. Right to object

If your personal data is processed to safeguard legitimate interests in accordance with Article 6 (1) sentence 1 (f) GDPR, data subjects have the right under Article 21 GDPR to object to processing of their personal data if there are grounds relating to their particular situation or the objection is to direct marketing. In the latter case, data subjects have a general right to object and we will comply with that right without any need for them to specify grounds relating to their particular situation. If you wish to make use of your right to revoke your consent or object to processing, simply send an e-mail to: webteam(at)usu.de

XI. Up-to-date status of and amendments to this Data Protection and Privacy Policy

This Data Protection and Privacy Policy is currently valid in its version dated May 2018. This Data Protection and Privacy Policy may need to be amended if our website and offerings are developed further or pursuant to changes in the law or official requirements.